Commentary on the Final Generic Environmental
Impact Statement for the World Trade Center Site

This latest document presented for comment in the process of rebuilding
the destroyed World Trade Center is yet another milestone in shameless
official disregard for public opinion while brazenly pretending to be
following it.

From Draft Scope to Final Scope to Draft GEIS to Final GEIS,
plan definitions have squirmed back and forth while determination
to push ahead with a plan tailored to pre-existing misconception
is rammed ahead full speed no matter what concerns are raised.

Governor Pataki remains determined to prevent anyone from having
a chance to undo his mistakes,lately moving up groundbreaking despite
the official review process still being underway.The accelerated
timetable has drawn protest from many quarters.

The GEIS does not bear the imprimatur of the Port Authority,though
it concerns the construction of Port Authority-owned buildings
on Port Authority-owned land.It is admitted that there is no agreement
with the development corporation to allow its plans to proceed.
This is a good thing,as the development corporation is not likely to
have to deal with the lasting consequences of its actions the way the
property owners are.However,political pressure to pave the way for
the horribly misconceived Proposed Action to proceed appears
inevitable.

The "Pre-September 11 Scenario" and "Restoration Alternative" are
explicitly recognized as benchmarks for the GEIS,after a prolonged
process in which such strategies for redevelopment have been implacably
opposed despite broad public support.However,official prejudice against
redevelopment based on restoration of what was destroyed ensures that
the GEIS seeks to portray these scenarios unfairly,in a bid to justify
the unreasonable programmatic requirements that have led to designs such
as the Proposed Action.

Numerous public comments urging the abandonment of the Proposed
Action in favor of the Restoration Alternative were received.
Reasoned arguments were reduced to one-liners in the Response
section and flippantly dismissed with regurgitated falsehoods
and invocations of unreasonable objectives.

It bears noting that no alternative drew close to the amount of
public interest and comment as the Restoration Alternative.
One entity each commented on the Memorial Only and Enhanced
Green alternatives,eight on the Reduced Impact,and none at all
on the others...but the Restoration Alternative was urged by
nineteen.In the initial comments,more people urged the Twin
Towers be rebuilt than expressed general approval of the Proposed
Action.

What are claimed to be preferable attributes of the Proposed
Action are NOT preferable to the Restoration Alternative in the
eyes of the public regardless of the brazen claim that the
Libeskind plan "achieved broad public support and fulfilled
many of the goals articulated by the public".

The Libeskind plan finished LAST in the OFFICIAL public
poll of the design process,which was won comfortably by "Neither"
(of the last two plans considered)...there is no question that
the priorities decided upon by the planners led to plans that
do NOT have public support,least of all this one.

To far more people than the development corporation will admit,
that the new World Trade Center be centered on towers every bit
as tall as the old by every measurement and representing
an updated reaffirmation of the design principles that produced
the original World Trade Center is

More important than the extension of any streets into or through
the site.

More important than "active enlivened street life".

More important than turning the distinctive quiet and low
population density of the Financial District into yet another of
the city's countless "24/7 communities".

More important than encouraging the disturbingly rapid growth of the
population of Downtown.

And to many,more important than leaving the "footprints" of the
former towers empty.(Before Governor Pataki aggressively intervened to
pre-empt public debate,polls showed New Yorkers evenly divided on building
on the old footprints).

All these issues must be given lower priority,and their merit subjected to
question rather than imposed as a design requirement.Honest evaluation of
adverse environmental impacts of encouraging population or traffic growth
either at the location in question or as a result of the decisions made
regarding what is to be built there are a must for a responsible
environmental impact statement.This one fails!

An environmentally conscious and appropriate redevelopment of the
World Trade Center would see that the way forward for Lower Manhattan
lies in further de-vehicularization,not the creation of more space for
future traffic jams and auto accidents.This is an area uniquely
suited to being dominated by pedestrian traffic arriving by mass
transit.

An environmentally conscious and appropriate redevelopment of the
World Trade Center would call for the concentration of the office
space into a smaller number of taller buildings than
in the Proposed Action.
Such construction would use less materials,less land,require less
construction equipment and activity with resultant disturbance and
proceed faster.Once constructed the scaled-up buildings would be
more efficient in operation and safer for their occupants because
they would be structurally stronger.Economies of scale would be
possible in new Twin Towers that would not be possible in the
much smaller Libeskind-plan buildings.

And such construction would leave more open space than before,
rather than less,as is the functional consequence of the Proposed Action,
which runs a street through what was one of the largest open spaces in
the area.

The GEIS constantly soft-pedals the hazards posed by proceeding on
the mistaken paths mandated by the development corporation.

Despite the substantial public pressure demanding a fair comparison
the Restoration Alternative remains a "straw man" in the Final GEIS,
barely touched from the unfair rendering in the Draft GEIS.The same
three slanted paragraphs of the Executive Summary attempt to dismiss
the Restoration Alternative as before.The characterization of the
Alternative,and the subjective design criticism,misplaced priorities,
and conveniently incomplete comparisons it is judged negatively for
not meeting,are barely touched in Chapter 23.The shameful use of
short-term market conditions created by the murderers as a reason
future development should implement their desires remains.

No flexibility is shown as to how the Restoration Alternative could
best meet objections,such as combining other uses into the two main
towers to increase open space.The placement of new Twin Towers is said
to be constrained by "the public's expressed desire for some meaningful
recognition of" the footprints of the old Towers,and "meaningful
recognition" creatively construed to mean total emptiness.To many,
reclamation of that space,even a symbolic portion of it,for the
purposes to which and for which the victims gave their lives is the
best recognition possible.And only with the placement contrived through
this constraint is the shadow effect any worse off the site than that
of the Proposed Action.Every effort is made to paint restoring the
Twin Towers as more inconvenient than it is.

This document in countless ways fails to fairly address the issues,
in the furtherance of its objective to ensure the implementation of
a disastrously wrong planning decision rather than permit wiser action.
Approval of the Proposed Action would be a disgrace to the city,to the
nation,and to the free world.